Legal basis: Art. 24-bis TUIR, introduced at €100k in 2017, raised to €300k from FY2023. Fixed annual tax on all foreign-source income for up to 15 years.

Who Is This For?

The €300,000 flat tax is optimal for: ultra-HNWIs with large foreign investment portfolios, entrepreneurs post-exit, family offices, trust/foundation income recipients, and retired executives with large foreign pension income.

Step-by-Step Guide

1
Confirm you meet the non-residency requirement
To access Art. 24-bis TUIR, you must not have been an Italian tax resident in at least 9 of the 10 tax years immediately preceding your application year. Italian tax residency is determined by: (a) registration in the anagrafe for more than 183 days in a year, (b) having your domicile (centre of vital interests) in Italy, or (c) having your habitual residence in Italy. If you were briefly registered in Italy in one of the previous 10 years, that year counts toward your residency history — but you still need 9 non-resident years out of 10.
2
File a preventive ruling request (interpello) with the Agenzia delle Entrate
Although not legally mandatory, filing a preventive ruling (interpello) under Art. 11 L. 212/2000 is strongly recommended before you relocate. The ruling asks the Agenzia delle Entrate to confirm you qualify for the flat tax regime. You submit: your personal details, tax residency history for the past 10 years (with supporting documentation such as foreign tax returns, foreign residency certificates, lease agreements abroad), and a declaration of your intended move to Italy. The Agenzia has 120 days to respond. A positive ruling gives you legal certainty before committing to the move.
💡 Tip: A ruling is not binding on you — if you receive it and decide not to move, there is no penalty. However, once you become Italian tax resident and opt into the regime, the ruling protects you from subsequent disputes.
3
Transfer your tax residency to Italy
Register your residence at the Ufficio Anagrafe of your Italian Comune. You become an Italian tax resident from the day you register. Obtain your Codice Fiscale (Italian tax ID) at the Agenzia delle Entrate — you will need this for everything: bank accounts, property purchases, utility contracts, tax filings. If you are relocating from a country with a tax treaty with Italy, notify your home country tax authority of the change of residency to avoid being considered a continued tax resident there (many countries have tie-breaker rules).
4
Elect the flat tax regime in your first Italian tax return
The flat tax election is made by checking the relevant box in your first Modello Redditi PF (Italian personal income tax return), filed by 30 November of the year following your first year of Italian tax residency. You must also attach a disclosure of all countries you intend to cover under the regime (you can exclude specific countries from the flat tax, meaning income from those countries remains subject to ordinary Italian IRPEF — useful if you want to benefit from foreign tax credits for income from certain jurisdictions).
5
Pay the €300,000 annual substitute tax
Each year you are under the regime, you pay a fixed €300,000 lump-sum substitute tax (imposta sostitutiva) on all your foreign-source income, regardless of how much you earned abroad. This payment is due by the ordinary tax payment deadline (typically 30 June, with a 0.4% surcharge to defer to 30 July). You also file a standard Modello Redditi PF showing Italian-source income (taxed at ordinary IRPEF rates) and the flat tax election for foreign income. IVAFE (foreign financial assets tax) and IVIE (foreign real estate tax) are also waived under the regime for most asset jurisdictions.
6
Add family members at €25,000 each
Your family members (spouse, children) can each opt into the flat tax regime at an additional €25,000 per person per year. Each family member makes a separate election in their own Italian tax return. This means a family of 4 (applicant + spouse + 2 adult children) could all benefit from the flat tax for a combined annual payment of €375,000 (€300k + 3 × €25k) — still extraordinarily efficient for a high-income family with multiple members generating foreign income.
7
Manage the 15-year duration and plan your exit
The flat tax regime lasts for a maximum of 15 consecutive years. You can voluntarily withdraw at any time (useful if your foreign income drops significantly). You cannot re-enter the regime after withdrawing or after the 15-year period ends. After the regime ends, you become a standard Italian tax resident subject to ordinary IRPEF (23–43%). Long-term planning is essential: many clients use the 15-year window to structure their affairs for eventual Italian citizenship, set up an Italian family office, or plan an orderly transition to a third country.

Key Numbers at a Glance (2026)

€300k
Annual flat tax
15yr
Maximum duration
€25k
Per family member
9/10
Non-resident years needed
120d
Ruling response time
0%
IVAFE / IVIE (most countries)

Tax Residency: How to Become (or Not Become) an Italian Fiscal Resident

The Flat Tax regime requires Italian tax residency — but this is precisely the strategic question for HNWI. Whether to establish Italian fiscal residency depends on your income level, global asset structure, family situation, and long-term plans. Here is the complete picture for 2026:

LEGAL FRAMEWORK: TUIR ART. 2 + D.LGS. 209/2023 Under Art. 2 TUIR as amended by D.Lgs. 209/2023 (effective 2024), Italian tax residency is triggered if — for more than 183 days/year — you are registered at the Anagrafe OR have your domicile (personal/family relationships centre) OR habitual abode in Italy. Anagrafe registration is now a rebuttable presumption, not an irrebuttable one.

How to Establish Italian Tax Residency (for the Flat Tax)

  • Obtain valid Italian residence rights (Investor Visa, EU freedom of movement, or other qualifying permit) and register at the local Anagrafe with proof of accommodation and a Codice Fiscale.
  • Deregister from your previous country's tax residency and obtain a deregistration certificate with the exact date — critical for proving the transition point and avoiding dual-residency disputes.
  • Verify non-Italian residency for the previous 9 of 10 years — the mandatory prerequisite for Art. 24-bis. The Agenzia delle Entrate verifies this via OECD Common Reporting Standard (CRS) data.
  • Elect the Art. 24-bis regime in your first Italian Modello Redditi PF. Pay €300,000/year as a substitutive tax covering all foreign-source income. Add family members for €25,000/year each.

How to Avoid Italian Tax Residency

Some HNWI choose to enjoy Italy's lifestyle without triggering Italian tax residency — preferring to manage their fiscal affairs from a more favourable jurisdiction. This is legally achievable with rigorous planning:

  • Stay under 183 days per calendar year — meticulously documented with travel records, hotel receipts, boarding passes, and foreign transaction data.
  • Maintain your domicile abroad: under the 2024 definition, 'domicile' means the place where personal and family relationships are principally centred. Keep your family's primary life, bank accounts, and social ties outside Italy.
  • Hold a valid tax residency certificate from a Double Tax Treaty country (OECD preferred). In any dispute with the Agenzia delle Entrate, OECD tie-breaker rules (permanent home → centre of vital interests → habitual abode → nationality) will determine residency.

✓ PRO: Italian Tax Residency + Flat Tax

Fixed €300k/year covers all foreign income — at €5M+ the effective rate falls below 6%
No IVAFE on foreign financial assets — eliminates 0.2%/year portfolio wealth drag
Full Italian quality of life: healthcare, Schengen, EU mobility, optional citizenship path

✗ CON: Italian Tax Residency + Flat Tax

€300k fixed cost — below ~€1–1.5M/year in foreign income, some other jurisdictions are cheaper
IVIE (0.76%) on foreign real estate still applies — significant for property-heavy portfolios
Exit tax on departure — structure shareholdings carefully before establishing Italian residency

For the complete 2026 legal framework — TUIR Art. 2, the D.Lgs. 209/2023 reform, 183-day rule, all special regimes, and full pros/cons — read our dedicated guide.

→ Read: Italian Tax Residency 2026 — Complete Legal Guide

Frequently Asked Questions

Does the €300k flat tax protect me from CRS/FATCA reporting?
No. The flat tax regime does not exempt you from Italy's CRS (Common Reporting Standard) or FATCA reporting obligations. You must still disclose foreign assets via the Quadro RW section of your Modello Redditi PF. However, IVAFE (the 0.2% annual tax on foreign financial assets) and IVIE (the 0.76% annual tax on foreign real estate) are waived for assets held in countries that have an adequate exchange of information agreement with Italy — which covers most OECD countries.
Can I earn Italian income while on the flat tax?
Yes, but Italian-source income is NOT covered by the flat tax. It is taxed at ordinary IRPEF rates (23–43% depending on bracket). The flat tax covers only foreign-source income. This is why many HNWI clients using the regime structure Italian activities carefully — for example, holding Italian real estate through foreign holding companies (though this requires careful tax structuring to avoid anti-avoidance rules).
What is the difference between the €300k flat tax and the Impatriate Regime?
They are mutually exclusive — you can only use one at a time. The €300k flat tax is best for HNWIs with large foreign income (e.g. investment income, dividends, capital gains from abroad) — you pay €300k regardless of how much you earn. The Impatriate Regime is best for workers and freelancers with Italian-source income — it exempts 50–70% of Italian employment/self-employment income but does NOT cover foreign income. If your income is primarily Italian-source, use the Impatriate Regime. If it is primarily foreign-source, the flat tax is almost always superior.
Can I buy property in Italy while on the flat tax regime?
Absolutely — and it is a common strategy. Purchasing Italian property while under the flat tax is entirely permitted. The property purchase itself is subject to standard Italian transfer taxes (imposta di registro 2% for first home, 9% for second home, or 4% + VAT for new builds from developer). Rental income from Italian property is Italian-source income taxed at ordinary IRPEF rates or the 21% cedolare secca flat rate for residential rentals. Purchasing Italian property can also support a future naturalisation application by demonstrating ties to Italy.